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July 26, 2002 Mr. Jeffery Stollenwerk Regional Supervisor Minnesota Pollution Control Agency 525 Lake Avenue South, Suite 400 Duluth, MN 55802 RE: Minnesota Pollution Control Agency’s Wastewater
Treatment Facility Operations Awards Selection Criteria Dear Mr.
Stollenwerk: The Minnesota Wastewater Operators Association (MWOA)
Executive Board met on July 23, 2002 and had discussed your request for input on
the selection criteria used in determining the recipients of the Wastewater
Treatment Facility Operations Award. We
are pleased that the Agency has recognized the deficiencies in this awards
program and that you have considered us for input for corrective actions. Many of our members feel there has been an unwarranted
elimination of facilities for consideration of these awards as the current
criteria is more focused on administrative compliance rather than the actual
performance of meeting effluent water quality limits. Since we have very diverse operations, we also believe that
the current process uses criteria that is not under the control of certain
wastewater operations and thus unfairly eliminates them for consideration of the
awards. It is unfortunate that the
system now places more emphasis on the proper documentation of any performance
rather than recognizing and promoting the excellent performance that is
controlled by the wastewater operators. We believe the latter was the original
intent of the Agency’s awards program and we would like to see it restored to
the prestige and credibility these awards deserve. We also do not want to make light of the administrative
obligations this profession has and may suggest that a tiered award program be
considered by the Agency for different levels of regulatory compliance.
Such a system may lend itself to better address the diverse levels of
operations and the variability of regulatory responsibilities represented by our
membership. In review of
your discussions to changes to the current criteria, we believe the Agency is on
course toward making progress in developing a more equitable process in
recognizing outstanding or excellent performance in our industry.
We would appreciate if you would update us on which items under
discussion have or will be incorporated in the final selection criteria. We are encouraging our membership to respond to your
request for input, as we believe there may be some apathy because of past
negative experience with your current criteria and selection process.
It may take additional mutual effort and time to restore this awards
program to the prestigious level it deserves. For further information on our organization’s position on
this issue and or for additional comments or clarifications, please contact our
Secretary/Treasurer Mr. Jim Miller Sincerely, Jerry Balbach, President Minnesota Wastewater Operations Association |
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